Wednesday, March 26, 2008

Ross Anderson, Rainer Böhme, Richard Clayton, and Tyler Moore have just published a 114-page study commissioned by the European Network and Information Security Agency (ENISA). The executive summary contains 15 recommendations for the European Union, most of which are just as appropriate for the United States.

We recommend that the EU introduce a comprehensive security-breach notification law.

We recommend that the Commission (or the European Central Bank) regulate to ensure the publication of robust loss statistics for electronic crime.

We recommend that ENISA collect and publish data about the quantity of spam and other bad traffic emitted by European ISPs.

We recommend that the European Union introduce a statutory scale of damages against ISPs that do not respond promptly to requests for the removal of compromised machines, coupled with a right for users to have disconnected machines reconnected if they assume full liability.

We recommend that the EU develop and enforce standards for network-connected equipment to be secure by default.

We recommend that the EU adopt a combination of early responsible vulnerability disclosure and vendor liability for unpatched software to speed the patch-development cycle.

We recommend security patches be offered for free, and that patches be kept separate from feature updates.

The European Union should harmonise procedures for the resolution of disputes between customers and payment service providers over electronic transactions.

We recommend that the European Commission prepare a proposal for a Directive establishing coherent regime of proportionate and effective sanctions against abusive online marketers.

ENISA should conduct research, coordinated with other affected stakeholders and the European Commission, to study what changes are needed to consumer-protection law as commerce moves online.

We recommend that ENISA should advise the competition authorities whenever diversity has security implications.

We recommend that ENISA sponsor research to better understand the effects of Internet exchange point (IXP) failures. We also recommend they work with telecomms regulators to insist on best practice in IXP peering resilience.

We recommend that the European Commission put immediate pressure on the 15 EU Member States that have yet to ratify the Council of Europe Convention on Cybercrime.

We recommend the establishment of an EU-wide body charged with facilitating international co-operation on cyber crime, using NATO as a model.

We recommend that ENISA champion the interests of the information security sector within the European Commission to ensure that regulations introduced for other purposes do not inadvertently harm security researchers and firms.